Federal Tax Crimes

Jack Townsend offers this blog on Federal Tax Crimes principally for tax professionals and tax students. It is not directed to lay readers -- such as persons who are potentially subject to U.S. civil and criminal tax or related consequences. LAY READERS SHOULD READ THE PAGE IN THE RIGHT HAND COLUMN TITLE "INTENDED AUDIENCE FOR BLOG; CAUTIONARY NOTE TO LAY READERS." Thank you.

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Federal Tax Crimes

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Good Article on the Non-Willfulness Certification for Streamlined and Related Issues (6/30/14)

U.S. International Tax Enforcement -- Exchange of Information and Collection (6/28/14)

Sentencing Tales Told in Spreadsheets (6/28/14)

False Statements Crime Element of "Knowingly and Willfully" Requires Proving Knowledge that Making False Statement Is Illegal (6/26/14)

Daugerdas Gets 15 Year Sentence (6/25/14)

New Policy on Not Approving Comments that Are Not Helpful to the Intended Audience of this Blog (6/21/14)

Comments by IRS Personnel on New Streamlined and OVDP Procedures (6/21/14)

The Credit Suisse / DOJ Negotiations (6/19/14)

The New Streamlined Processes' Requirement of Certifying Non-Willfulness (6/19/14; rev'd 6/21/14)

IRS Issues More Liberal Streamlined Procedures and Makes Some Changes to OVDP (6/18/14)

Israel Focuses on Offshore Accounts (6/18/14)

The Cost of Tax Havens - An Analysis of Empirical Data (6/16/14)

11th Circuit Holds Clear and Convincing Evidence Required for Section 6701 Penalty; Can Reasoning be Extended to FBAR Willful Penalty? (6/14/14)

More On Willfulness (6/13/14)

France Goes after French Depositors in Swiss Banks and the Swiss Banks Also (6/12/14)

Swiss Banks' Requests to U.S. Depositors for Waivers and Proof of Entry Into OVDP (6/11/14)

BDO Seidman Personnel Sentenced for Bullshit Tax Shelter Promotion (6/11/14)

Reminder: Category 2 Banks Will Serve Up Their U.S. Depositors (6/11/14)